Can the officers search the automobile again two hours later without obtaining a new consent to search?

Answer 1

This would depend on the reason the car was searched in the first place, and the circumstances at the time of the second search. If permission is given to search (a consent search), the permission can be withdrawn. If the officers have not developed probable cause to continue searching, the search must stop. In the sceanario described, it is possible that probable cause developed to search the vehicle a second time. If so, then the search would be permissible. If the first search was by consent and the consent was not withdrawn, then one could argue that a consent search could resume two hours later.

Additional: Also - if the vehicle was impounded and towed to a secure facility, an "inventory search' may be conducted to inventory. account for, and secure any property contained in the vehicle. However such an "inventory search" may not be used as a subterfuge for searching for, and seizing, any contraband or evidence which the vehicle may contain. For that purpose, a search warrant would still have to be applied for and granted.